RonObvious
Senior Member
- Joined
- Nov 21, 2016
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Question about naming one's enterprise "XYZ Vineyards" vs. "XYZ Winery."
So we're finally in the last stages of being able to sell to the public. LLC business has been created, we've got our permit from the TTB, state, FDA, etc. etc... the LAST step on the list is to get a COLA. So now that the government is back open, I figure the timing is perfect for me to submit the COLA application for our first label. I'm reading through the documentation about image size and all that and happen to notice something I hadn't before:
"If a brand name includes a vineyard, orchard, farm, or ranch name, at least 95 percent of the contents must come from the vineyard, orchard, farm, or ranch referred to in the name."
A few years ago we purchased some land and started growing grapes. Our grapes are starting to come into production but at the moment we're still supplementing with juice/grapes from the Finger Lakes. Obviously we look forward to the day we can grow 100% of what we produce, but we aren't there yet and won't be for a few more years.
So the question is, can I submit a label with our brand being "XYZ Vineyards" even though the vineyard itself is not yet producing at least 95% of the grapes?
When I first read the regulation my heart sunk because I've already done all the above paperwork with the TTB, state, etc. as "XYZ Vineyards." Going back and re-doing it would be a MAJOR headache and loss of time. But then I remembered some other examples (not naming names) of other wineries in the area that I KNOW are doing the same thing (buying grapes from somewhere else) and still call themselves a "Vineyard" on the label.
I could call the TTB and get my question answered today, but since this is their first day back on the job after the shutdown I don't want to bother them. Plus I want to see what others' experience has been first. Thanks in advance!
So we're finally in the last stages of being able to sell to the public. LLC business has been created, we've got our permit from the TTB, state, FDA, etc. etc... the LAST step on the list is to get a COLA. So now that the government is back open, I figure the timing is perfect for me to submit the COLA application for our first label. I'm reading through the documentation about image size and all that and happen to notice something I hadn't before:
"If a brand name includes a vineyard, orchard, farm, or ranch name, at least 95 percent of the contents must come from the vineyard, orchard, farm, or ranch referred to in the name."
A few years ago we purchased some land and started growing grapes. Our grapes are starting to come into production but at the moment we're still supplementing with juice/grapes from the Finger Lakes. Obviously we look forward to the day we can grow 100% of what we produce, but we aren't there yet and won't be for a few more years.
So the question is, can I submit a label with our brand being "XYZ Vineyards" even though the vineyard itself is not yet producing at least 95% of the grapes?
When I first read the regulation my heart sunk because I've already done all the above paperwork with the TTB, state, etc. as "XYZ Vineyards." Going back and re-doing it would be a MAJOR headache and loss of time. But then I remembered some other examples (not naming names) of other wineries in the area that I KNOW are doing the same thing (buying grapes from somewhere else) and still call themselves a "Vineyard" on the label.
I could call the TTB and get my question answered today, but since this is their first day back on the job after the shutdown I don't want to bother them. Plus I want to see what others' experience has been first. Thanks in advance!
